On 9 September 2015, the U.S. Court of Appeals for the Second Circuit issued a combined opinion affirming that the economic substance doctrine applies to the foreign tax credit regime generally. The opinion is in regard to two cases: The first involving a trust transaction of New York Mellon Corp and alleged tax deficiencies of approximately USD 215 million, and the second involving cross border transactions of American International Group and a refund claim of USD 306.1 million. In its opini…